Whistleblowing at Scale: building a program across borders

• A comparison of the EU, UK, and US regimes that separates hard legal obligations from expectations, incentives, and good practice
• A program architecture diagram covering reporter access, local intake and triage, case management, governance, and board reporting, with the design considerations at each layer
• A checklist for evaluating a partner, in five areas: coverage, case management depth, architectural flexibility, security posture, and track record
• The five capabilities cross-border programs need beyond the single-jurisdiction checklist of confidentiality, anonymity options, multilingual access, case management, and timestamped records
• How Teleperformance kept 14 subsidiary brand intakes intact after the Majorel acquisition while consolidating onto one case management model
• Three framings that work when the investment case goes to budget holders

Chief Compliance Officers, Heads of Compliance, and group speak-up program owners at multinationals with entities across the EU, UK, and US.

The EU requires internal channels at private entities with 50 or more workers, with resource-sharing limited to entities of 50 to 249 and implementation varying across 27 Member States. The UK has no general channel mandate, though sector rules apply to some organizations, and the ECCTA fraud-prevention guidance in force since September 2025 treats whistleblowing and investigations as governance indicators. The US has no general mandate either, and sector rules such as SOX require channels in scope while the DOJ’s March 2026 Corporate Enforcement Policy rewards companies that identify serious misconduct early enough to investigate it, remediate, and preserve the option to self-disclose.

Programs are judged on four things: whether reporters can access them locally, whether cases are handled consistently across jurisdictions, whether confidentiality holds through investigation, and whether leadership can act on reliable case data. Deploying a hotline globally meets one of the four.

Integrity Line is designed for all four.

• Local access: reporting through web, phone, email, and proxy channels, with local-language intake and local legal-entity access where the EU Directive requires it.
• Consistent handling: multiple reporter-facing brands feeding one case management model, so cases can be handled to the same governance standard across countries.
• Confidentiality through the investigation: role-based access, two-factor authentication, end-to-end encryption to BSI standards, and ISO 27001-certified hosting with regional data residency options.
• Case data leadership can act on: structured case records and data export for board reporting, with a complete record of who did what and when.

Explore EQS Integrity Line